It’s not quite as confusing as it looks…
Anyone who has been paying attention to the new 107 rules rollout has to give the FAA some serious props (pun intended), even if they don’t necessarily agree with all of the new rules. Even with the new administration imposing the delays on the DOT, the overall rollout of the new night ops and over people ops went pretty smooth.
At least until we got to night ops in controlled airspace. That’s where the ease of use train derailed…
So we at DSPA thought this would be a good subject for an article written in plain English. Hopefully this will make sense. It is a bit confusing, but at least it’s temporary.
The main issue comes about because the LAANC system is not set up to handle any airspace requests that fall outside of daylight hours (yet). In order to accomplish night flights in controlled airspace, you have to apply for a 107.41 Authorization, and attach your 107.29 Daylight Waiver. With the 107.29 being “terminated” by the FAA on 5/17, that system is will no longer be viable.
The LAANC system isn’t going to be ready for non-daylight ops until “Fall of 2021”. So until then we are in an unofficial limbo for a process to fly at night in controlled airspace.
This is where National Authorization, FAA Form 7711-1, 14 CFR Part 107 LAANC Night Operations Certificate of Waiver or Authorization comes into the story. And the official process for using Form 7711-1 is here , but we’re going to digest that page in this article. So that link if for your reference only.
First requirement for any night operation under the new 107.29 rules is that the 107 Pilot must have taken the new FAASafety.gov training (ALC-677) or new Initial 107 in-person test on or after 4/6/21. That applies to any night ops for uncontrolled airspace too.
There are now two ways to apply for permission under for night ops in controlled airspace. Both LAANC and 107.41 Airspace Authorizations can be used.
If you want to fly in a LAANC active airport at or below UASFM maximums, use your favorite LAANC USS (Skyward, KittyHawk, UASidekick, etc.) and apply for a standard LAANC approval for the day you want to fly. Make sure you only apply for daylight hours. If you try to include the night hours, it will automatically deny the application.
Example: if you want to fly at 10:30PM on May 4th, you apply for a LAANC approval for daylight hours on May 4th and carry your 7711-1. If you need to fly at 3:30AM on May 5th, you need to apply for a LAANC approval for daylight hours for May 5th and carry 7711-1 with you. If your flight carries over past midnight, you simply apply for two LAANC approvals, one for each of the dates for daylight hours and carry your 7711-1.
You must download FAA 7711-1 (link above), and carry that with you along with your LAANC approval. 7711-1 extends your LAANC approval past daylight hours. It extends your LAANC approval to the hours between civil sunset and/or civil sunrise. So that also includes civil twilight. You can use either a paper copy or a digital copy. Or, both if you’re like me and always want a backup. And daylight LAANC authorization requests that fall under UASFM limits are real time, and virtually instant.
If you want to fly at a non-LAANC active airport, you simply use the Drone Zone portal and apply for a standard 107.41 Airspace Authorization. Just put the hours you need to fly, and fill out the form as you’re always done it. 107.41 applications are NOT instant, and you need to give the FAA as much time as possible. If they have not been reviewed within 24 hours of the listed flight times, your application will be automatically denied. I try and give ATC at least 7 days notice. Even more if at all possible.
Also, multiple day Wide Area Authorizations in a LAANC active airport are no longer an option. If you need multiple days for things such as weather delays, use multiple LAANC requests.
If you need to apply for flights outside UASFM limits at night, you can use either LAANC or the Drone Zone. As with non-LAANC airports, you need to give ATC as much time as possible to process the request. You can apply for manual LAANC requests (those outside UASFM limits, also called “Further Coordination Requests”) can be requested up to 90 days in advance. As can automated LAANC requests. This may depend on your LAANC USS provider. If your current USS doesn’t have that option, try a different one.
Multiple day 107.41 Airspace Authorizations for non-LAANC airports are still active.
So, recap:
~Use LAANC when available, and simply apply for a daylight approval for the date you need to apply. Then carry your 7711-1 with you in order to extend past daylight hours.
~Use Drone Zone for non-LAANC airports to get your night ops approval. Also carry the 7711-1 with you for those.
~Requests outside UASFM limits can use either method, but take extra time. Plan accordingly.
~And of course, you must have taken your 107 Initial Test, or 107 Online Recurrent Training on or after 4/6/21 to take advantage of ANY night operations, controlled airspace or not.
We hope this helps answer some of the questions that have arisen over 107 night ops in controlled airspace.
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